GR 209551; (February, 2021) (Digest)
G.R. No. 209551 , February 15, 2021
Felino A. Palafox, Jr., Petitioner, vs. Hon. Francisco G. Mendiola and Senator Edgardo J. Angara, Respondents.
FACTS
Private respondent Senator Edgardo J. Angara filed a Complaint for Damages against petitioner Felino A. Palafox, Jr. in the Regional Trial Court (RTC) of Pasay City, alleging that Palafox, Jr. authored an unsigned letter containing defamatory statements. In the Complaint, Sen. Angara indicated he was holding office in Pasay City. Palafox, Jr. moved to dismiss the case for improper venue, arguing that the complaint should have been filed in Makati City where both parties reside. He contended that Article 360 of the Revised Penal Code, which allows filing where a public officer holds office, was inapplicable because the action was a purely civil action for damages with no criminal case for libel filed. Meanwhile, Sen. Angara served a notice to take Palafox, Jr.’s deposition upon oral examination. Palafox, Jr. opposed this, arguing deposition was premature as pre-trial had not been terminated. The RTC, in its July 11, 2013 Order, denied the motion to dismiss, ruling venue was proper under Article 360, and granted the motion to take oral deposition pursuant to Rule 23 of the Rules of Civil Procedure. The RTC denied Palafox, Jr.’s motion for reconsideration in its September 20, 2013 Order. Palafox, Jr. filed a Petition for Certiorari directly with the Supreme Court, raising issues on the applicability of Article 360 to a purely civil case and the propriety of taking deposition before pre-trial termination. Sen. Angara, in his Comment, argued, among others, that Palafox, Jr. violated the rule on hierarchy of courts by filing directly with the Supreme Court.
ISSUE
Whether the Petition for Certiorari should be dismissed for violation of the rule on hierarchy of courts.
RULING
Yes. The Supreme Court dismissed the Petition for violation of the rule on hierarchy of courts. The Court emphasized the principle that direct recourse to the Supreme Court is improper as it is a court of last resort, and the policy is designed to allow the Court to focus on its constitutional tasks. Exceptions to this rule require special and important reasons clearly stated in the petition. In this case, Palafox, Jr. filed his Petition directly with the Supreme Court despite the concurrent jurisdiction of the appellate court. He did not provide any reason or explanation to justify this non-compliance. Furthermore, when required to reply to Sen. Angara’s argument on the violation of the hierarchy of courts, he merely manifested adoption of his previous arguments. This constituted a clear disregard of the hierarchy of courts, meriting the dismissal of the Petition. The Court did not reach the substantive issues raised regarding venue and deposition.